On November 13, 1995, a mild winter afternoon, a golden retriever named Bandit went with his caregiver for a walk along a road in Wisconsin’s Trempealeau National Wildlife Refuge. Among the smells in the air was a mouth-watering scent that Bandit could not resist. Too late, caregiver and dog learned that the aroma came from bait set in a Conibear trap to catch a raccoon.

Bandit’s head was completely caught in the trap. Despite all his efforts, Bandit’s caregiver could not remove the trap before the dog suffocated to death in his arms.

The trap was perfectly legal, placed under a permit obtained by a trapper from the refuge, which annually sells exclusive rights to trap muskrat, beaver, and raccoon in certain areas. But neither Bandit nor his caregiver had known of the trap, and Bandit paid the price.

Tragedies All Too Frequent

This horror story¹ is hardly an isolated incident. Across the United States’ system of National Wildlife Refuges (NWRs), tragedies like this one are all too frequent.

More than half of our national refuges allow trapping and hunting of wildlife. These are public lands, and technically those lands and wildlife belong to us all. Yet refuge regulations permitted the Trempealeau trapper to set his Conibear trap for “recreational or commercial” purposes. Legally, he may have been targeting muskrat, beaver, raccoon, skunk, or mink, all animals primarily targeted for their fur. But traps do not discriminate, and many non-target victims, like Bandit and other companion animals and even endangered species, fall victim to body-gripping traps.

Whenever API receives calls, articles, and letters about tragic stories such as Bandit’s, we contact various government agencies and public officials to try to learn why this killing of wildlife continues to be condoned. Almost invariably, the blame is placed on the companion animal's guardian, never the trapper. And the trappers know it. Indeed, reporters quoted the Trempealeau trapper as saying, “dog owners [must] be vigilant around their animals during trapping seasons no matter where they are.”

Less than 0.01% of the U.S. population traps. Why then must the other 99.9% “be vigilant” about unseen and unknown traps when visiting a refuge, when refuges were originally set up by President Theodore Roosevelt to “preserve wildlife and habitat for people today, and for generations to come”?²

It’s going to get worse, not better. On October 9, 1997, President Clinton signed into law the 1997 National Wildlife Refuge Improvement Act (also known as the NWR Organic Act), which designates hunting and fishing as “priority uses,” and stipulates that these “priority uses” “shall receive enhanced consideration” by the refuge manager. In consequence, more refuges will likely be opened to consumptive wildlife uses, including hunting, fishing and trapping. Yet national Fish and Wildlife Service statistics show that of the 27.1 million refuge visitors in 1995, 81.5% visited refuges to view and photograph wildlife, for environmental education, and similar non-consumptive recreational pursuit. Only 4.5% of refuge visitors went there to hunt or trap wild animals.³

While the Act makes it more difficult for secondary uses such as grazing, mining, and logging to take place on refuges, it does nothing to stop recreational killing of wildlife. Sponsors pushed the Act through Congress with claims of an over-arching mission for the refuge system of “conservation.” Instead, it has boosted the status of wildlife-killing activities. No wonder that the sponsors turned out to be “sportsmen’s” organizations such as the National Rifle Association, Safari Club International, Ducks Unlimited, and the Wildlife Legislative Fund of America. This is a small but politically powerful minority who worked behind the scenes to ensure that the new Act guaranteed “priority” status of their bloodsports.

How Did We Get Here?

The first National Wildlife Refuge was established in 1903, and hunting, trapping, and other activities inimical to preserving wildlife were prohibited on all refuges. By 1950, however, as a result of the duck stamp program, many refuges began to allow hunting and trapping. The duck stamp program enabled consumptive wildlife users to argue that their contribution to so-called conservation gave them the inalienable right to kill wildlife on public lands.

Today in 517 refuge units that encompass 92 million acres in all 50 states, 280 refuges allow trapping and 287 allow hunting.

More than 3,000 Waterfowl Production Areas (WPAs), mostly in the Midwest, are part of the refuge system. Under the guise of “avian conservation” these areas cater to waterfowl hunters and trappers, with management focused on eliminating bird- and egg-eating predators such as foxes, coyotes, raccoons, and skunks. To accomplish this reprehensible task, a national “Predation Avian Recruitment Team” has been developed under the auspices of the International Association of Fish and Wildlife Agencies. Their mission is to increase the number of pheasants, quail, turkey, and waterfowl (i.e. hunting targets) within the refuge system by “surgically removing” predators. Trappers may trap predators on WPAs without a permit, which is normally required to trap on a refuge. The fact that the same traps set to target certain predators sometimes kill the very species they are intended to protect doesn’t appear to concern the U.S. Fish and Wildlife Service (FWS), the agency charged with management of the refuge system.

Old News

But this cruelty is old news. More than forty years ago, a six-year study at Alabama’s Wheeler National Wildlife Refuge noted that of 1,886 animals trapped in leghold traps on the refuge, 27% of all mink, 24% of all raccoons, and 26% of all foxes trapped were considered “crippled” (defined as “all animals that pulled out of the traps, escaped by wringing-off or gnawing feet, or escaped with the traps” attached to their limbs).⁴ The primary purpose of the Wheeler National Wildlife Refuge is to produce waterfowl for hunters. Trapping with body-gripping devices is still allowed today, and it is likely that scores of both target and non-target animals continue to be crippled in the process.

Since its inception, the National Wildlife Refuge System (NWRS) has been administered under a collection of presidential proclamations, executive orders, administrative orders, and laws. The Refuge Recreation Act of 1962 authorized “recreational uses” of NWRs, further expanding hunting, trapping, grazing, mining, and other activities harmful to wildlife. In 1966, a “compatibility standard” for allowing public uses on refuges was established with passage of the National Wildlife Refuge System Administrative Act. The FWS defines “compatible use” as “a wildlife-dependent recreational use or any other use of a refuge that, in the sound professional judgment of the Director, will not materially interfere with or detract from the fulfillment of the Mission of the System or the purposes of the refuge. The action must also be in accordance with the principles of sound fish and wildlife management and administration, and otherwise must be in the public interest.”

Today, before a refuge is opened up to hunting or fishing, the FWS must first go through the NEPA (National Environmental Policy Act) process and allow the public to submit comments on the issue. However, no such public comment process is required for a refuge to allow trapping. It is up to individual refuge managers to decide if trapping is “compatible” with the purpose of the individual refuge.

How’s That Again?

How refuge managers find trapping compatible with protecting and recovering the 240 listed endangered species (24% of all listed species) that inhabit refuges is a baffling question. And yet, boasts the FWS, “We watch over 700 kinds of birds, 220 mammals, 250 reptiles and amphibians and 200 kinds of fish ... it is here they [threatened and endangered species] often begin their recovery or hold their own against extinction”.⁵ How can a species “hold [its] own against extinction” when more than 60% of refuges tolerate harmful activities to wildlife, including mining, oil and gas drilling, cattle-grazing and timber-cutting?⁶

Further, how is allowing trapping on refuges in “the public interest” when less than 1% of the population traps? It’s hardly a major industry, not when trapping expenditures — replacement traps, licenses, lures, travel expenses, and so on — actually exceed average annual trapping income for Northeast trappers by almost $1,000.⁷ Yet trappers also have access to millions of acres of public lands outside the NWRS to practice their cruel profession.

This runs so contrary to public opinion it’s shameful. In a 1996 Caravan poll, 74% of Americans expressed opposition to the use of leghold traps. In a 1995 Associated Press poll, 59% said they opposed the trapping of animals for fur.

Public Outcry

By 1997, public outcry against trapping on the National Wildlife Refuge System prompted Congress to include language in the 1997 Appropriations Bill directing the FWS to convene a task force to “study the use of animal traps in the National Wildlife Refuge system ... [and to] consider the humaneness of various trapping methods ... and other relevant issues.” It also stipulated that the task force “include interested outside parties.”

The FWS argued that a task force could not be convened in the allotted time, and convinced Congress to replace the task force with a nationwide survey. API’s opinion is that time was not the issue; instead, the FWS did not want to have to “include interested outside parties” who might oppose trapping on refuges.

So in January 1997 the FWS distributed a detailed two-part questionnaire to every National Wildlife Refuge unit manager in the United States. Surveyed were all lands in the National Wildlife Refuge System, including 517 wildlife refuges, wildlife ranges, wildlife management areas, easements, and coordination areas.

A notice published in the Federal Register allowed the public less than 60 days to submit comments on the issue of “the use of animal traps within the National Wildlife Refuge System.” Despite this short comment period, the FWS received 969 public comments, and in May forwarded four volumes of unedited public comments to the Chairmen of the Appropriations Subcommittee on Interior & Related Agencies, as well as a summarized version of the NWR questionnaires.

Tell It Like It Is?

In its final 87-page summary report submitted to Congress, the FWS offered a glowing, even self-serving, account of the benefits of trapping to National Wildlife Refuges. The report concluded that trapping on refuges is “a professional wildlife management tool” that provides “important benefits for public health and safety and recreational, commercial, and subsistence opportunities for the public.”

This virtual “snow job” told Congress and the public that trapping on refuges is conducted primarily for “facilities protection” and for the protection of migratory birds and threatened and endangered species. Trapping for “recreation/commerce/subsistence” is listed as the last of eleven reasons for trapping in the NWRS.

Not true, as API learned when we obtained a copy of the raw survey data through the Freedom of Information Act. We found that the FWS’s official conclusions did not accurately reflect the information submitted by the refuge managers.

Our analysis of the questionnaire data, calculating the total percentages, found that the most common purpose cited by refuge managers for trapping was for “recreation/commerce/subsistence.” Clearly, the FWS was obscuring the truth that most trapping on refuges is by fur trappers, not by anyone trying to “protect rare species.” The FWS not only twisted information to form a particular conclusion (trapping is necessary and a good “wildlife management tool”), but excluded vital data, such as types of traps used and the incidents of non-target species trapped on refuges.

Who's in Charge Here?

Before submitting our February 1997 comments on trapping on the NWRS, API discovered many violations of the laws and acts governing the NWRS. We also found that the managers within the system were ignorant of the correct procedures.

The 1982 FWS Trapping Refuge Manual explains the law requiring all refuge managers who allow trapping on refuges in their state to conduct an Environmental Analysis and to develop a refuge “Trapping Plan.” Each refuge regional director must compile “an environmental analysis (EA) of the significance of anticipated impacts of a refuge trapping program,” and these trapping plans “will be maintained for each National Wildlife Refuge upon which trapping of furbearing animals is permitted. Public participation will be included in the development of the trapping plan.”

It sounds good on paper, anyway. In reality, when API contacted the FWS Refuge Trapping Program Specialist, he did not have a single EA or Trapping Plan from one refuge. Nor did he know the number of refuges that actually allow trapping. Whether the refuge managers failed to carry out their individual mandates, as required by NEPA, or the FWS failed to compile such data from each individual refuge, it is clear that our government is not managing the refuge system according to the law.

Making It Stop

API believes that trapping should be prohibited on all refuges. Humane concerns aside, trapping is not compatible with the preservation of threatened and endangered species that inhabit refuges. In fact, trapping poses a serious hazard to many of these species and may actually hinder their recovery. As the only public lands in the U.S. specifically set aside to provide animals a safe home, refuges should be maintained as inviolate sanctuaries for wildlife, not as recreational playgrounds for trappers and other consumptive wildlife users.

Public visitors to refuges expect to be safe, to have the opportunity to view animals, without the fear of stepping into a trap, or having to witness the pain and suffering of a trapped animal.

Today, four volumes of public commentary on the subject of trapping on National Wildlife Refuges sit untouched in the offices of House and Senate Appropriations Committee members. Not only must we ensure that these comments are read and acted upon as Congress directed, we must expose the deceit behind the FWS’s summarized report of trapping on the NWRS.

API's own report on the questionnaire data, Trapping on National Wildlife Refuges: The History and Current Status of Trapping on the National Wildlife Refuge System, has been sent to key members of Congress and more than 50 national and grassroots organizations across the United States.

We hope that this publication will help in efforts to ban trapping on the refuge system. We must convince Congress and the American people that there is no justification for allowing this cruel practice to continue on public lands the FWS claims are “the only system of federal lands devoted specifically to wildlife” serving “as havens for hundreds of endangered species.”⁸ The National Wildlife Refuge System belongs to all Americans. It is time the management of the NWRS reflect the values and sentiments of the majority of Americans who visit refuges not to kill wildlife, but to enjoy nature, undisturbed by humans.

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Notes

1. “Trap Kills Dog at Refuge.” Winona (Wisconsin) Daily News, November 22, 1995.
2. The National Wildlife Refuge System: Promises for a New Century. Washington, DC: United States Fish and Wildlife Service.
3. United States Fish and Wildlife Service, Division of Refuges.
4. Thomas Z. Atkenson. “Incidence of Crippling Loss in Steel Trapping.” Journal of Wildlife Management, Vol. 20, No. 3, July 1956.
5. Promises for a New Century.
6. U.S. General Accounting Office report, 1990.
7. Dave Hamilton et al. Ownership and Use of Traps by Trappers in the United States in 1992. The Fur Resources Committee of the International Association of Fish and Wildlife Agencies, 1994.
8. “Landmark Law Charts Bright Course for Management of the National Wildlife Refuge System.” United States Fish and Wildlife Service press release, October 9, 1997.